August 21, 2018

August 21, 2018

Subscribe to Latest Legal News and Analysis

August 20, 2018

Subscribe to Latest Legal News and Analysis

Belgium Finds Quality of Nanoregistrations Can Be Improved

The Belgian Federal Public Service for Public Health, Food Chain Safety and Environment has published the first annual report for nano substances registered for placement on the market in 2016.  Although the report is available only in French and Dutch at this time, each contains an executive summary in English.  Of the 475 registrations submitted, importers submitted 56 percent of the registrations, distributors 22 percent, and manufacturers 11 percent.  The rest were submitted by formulators or “others.”  According to the executive summary, NACE(BEL) Code 20, manufacture of chemicals and chemical products, was used most often to describe the economic activity at the level of the company.  At the level of the registrations, Code 20160, manufacture of plastics in primary forms, was used most frequently.  In 2016, 57,550 tons of substances in nanoparticular state were imported, 16,947 tons were manufactured, and 13,815 tons were distributed.  Substances registered in quantities greater than 1,000 tons include amorphous silica, calcium carbonate, calcium carbonate treated with stearic acid, carbon black, diiron trioxide, iron hydroxide oxide yellow, and silicon oxide.  About half of the submitted registrations reported quantities below one ton.  The executive summary states that evaluation of the submitted registrations shows that the quality of the registrations can be further improved.  It also suggests the possibility that not all potential registrants are aware of the May 27, 2014, Royal Decree and the obligation to register.  The nominative list of the substances registered for 2016 is presented in an annex to the report.  Based on the Chemical Abstracts Service (CAS) number, about 150 different chemical substances were identified.  The executive summary notes that the chemical identification makes no distinction between the possible differences in the physico-chemical properties of the nanosubstances.

©2018 Bergeson & Campbell, P.C.

TRENDING LEGAL ANALYSIS


About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Owner of Bergeson & Campbell, P.C. (B&C®), Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy...

202-557-3801
Carla Hutton, Bergeson Campbell PC, global regulatory attorney, public health activists lawyer, metals industry legal counsel, Toxic Substances Control Act law
Regulatory Analyst

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client initiatives. These tasks have proven invaluable to many clients, keeping them aware and abreast of developing issues so that they can respond in kind and prepare for the future of their business.

Ms. Hutton brings a wealth of experience and judgment to her work in federal, state, and international chemical regulatory and legislative issues, including green chemistry, nanotechnology, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), Proposition 65, and the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program.

202-557-3809